**Facts:**
The City Council of Baguio enacted Ordinance No. 386 on February 23, 1967, aiming to address the squatting issue by considering registered squatters as bona fide occupants of their respective lots, which were to be included in a city government housing project. The ordinance provided regulations on building permits, pending court cases against squatters, and financial matters related to the acquisition of lots by squatters. Despite its intentions, the Baguio Citizens Action Inc. and the Junior Chamber of Baguio City, Inc. filed a petition for declaratory relief with the Court of First Instance of Baguio, Branch II, to declare the ordinance invalid and illegal ab initio. The respondents moved to dismiss the petition, but their motions were denied. However, the court still dismissed the petition based on grounds including judicial respect for another court’s ruling, a jurisdictional defect caused by the non-joinder of affected parties, and the discretion to refuse declaratory judgment under certain conditions.
**Issues:**
1. Whether the City of Baguio’s Ordinance No. 386 was within the legal powers of the city council to enact.
2. Whether the non-joinder of squatters as parties to the petition for declaratory relief constituted a jurisdictional defect.
3. Whether Ordinance No. 386 was a valid measure to legalize squatter settlements within the city.
**Court’s Decision:**
The Supreme Court nullified Ordinance No. 386, finding it to be a patent nullity. It held that:
1. The city council lacked the authority to legalize squatting on public land, as such actions require prior legislative approval given the exclusive control, administration, disposition, and alienation of public lands lie with the Director of Lands.
2. The non-inclusion of squatters as party defendants did not constitute a jurisdictional defect; rather, it was a matter related to the effectiveness of any declaratory judgment. The real party in interest was the City Council, making the ordinance’s validity primarily a legal issue beyond the squatters’ participation.
3. Squatting cannot be legitimized through local ordinances as it contravenes fundamental legal principles and governmental policies against squatting, undermining respect for lawful property rights and government authority.
**Doctrine:**
– Local government units cannot legalize squatting or circumvent national laws and policies concerning public land without explicit legislative authority.
– The non-joinder of affected parties in declaratory relief actions does not necessarily constitute a jurisdictional defect if the judgment would not practically impair their rights or interests.
**Class Notes:**
– **Public Land Act:** The legal framework governing the administration, classification, lease, sale, or any other form of concession or management of lands of the public domain.
– **Local Government Authority:** Local government units have limited powers in enacting ordinances, particularly concerning issues that require national legislative authorization, such as disposition of public land.
– **Squatting:** Illegal occupation of land, regardless of attempts to legitimize through city ordinances, remains unlawful and against public policy.
– **Declaratory Relief:** A judicial remedy for clarifying legal rights or the legality of ordinances, where effective judgments require the joinder of all necessary parties affected by the declaration.
**Historical Background:**
The case exemplifies a time when local governments, facing urban development pressures and housing issues, attempted to address squatting through local ordinances. However, this decision reaffirms the principle that solutions to complex matters like squatting and public land disposition must align with national legal standards and require legislative backing, underscoring the hierarchical structure of law and the need for coherence between local initiatives and national policy.
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